foreign personal holding company
1foreign personal holding company — A foreign corporation, the primary part of the income of which is personal holding company income and the stock of which is owned to the extent of 50 percent in value by less than six individual United States citizens or residents. IRC § 554 …
2foreign personal holding company — Abbr. FPHC A foreign corporation in which (1) 60 percent or more of the gross income for the taxable year is FPHC income and (2) more than 50 percent of the total combined voting power or the total value of the stock is owned, directly or… …
3foreign personal holding company — Abbr. FPHC A foreign corporation in which (1) 60 percent or more of the gross income for the taxable year is FPHC income and (2) more than 50 percent of the total combined voting power or the total value of the stock is owned, directly or… …
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